Joe Arpaio Files Defamation Complaint Against CNN, Other Media

Case 1:18-cv-02894 Document 1 Filed 12/10/18 Page 1 of 10
IN THE UNITED STATES DISTRICT COURT

DISTRICT OF COLUMBIA
JOSEPH MICHAEL ARPAIO, an individual

Fountain Hills, AZ
Plaintiff,
v. Case No.:
JEFF ZUCKER, an individual
c/o Cable News Network
1 CNN Center COMPLAINT
Atlanta, GA, 30303
And
CHRIS CUOMO, an individual
1 CNN Center
Atlanta, GA, 30303
And
CABLE NEWS NETWORK, a corporation
1 CNN Center
Atlanta, GA, 30303
And
KEVIN ROBILLARD, an individual
c/o Huffington Post
770 Broadway
New York, NY 10003
And
HUFFINGTON POST, a corporation
770 Broadway
New York, NY 10003
And
TESSA STUART, an individual
c/o Rolling Stone
1290 Avenue of the Americas
New York , NY 10104
And
ROLLING STONE, a corporation
New York, NY 10104
1
Defendants.
I. INTRODUCTION
Plaintiff Sheriff Joseph Michael Arpaio (“Plaintiff Arpaio”) brings this Complaint for
defamation and false light against Jeff Zucker (“Zucker”), Chris Cuomo (“Cuomo”), Cable News
Network (“CNN”), Kevin Robillard (“Robillard”), Huffington Post (“HuffPo”), Tessa Stuart
(“Stuart”) and Rolling Stone (“RS”).
II. JURISDICTION AND VENUE
1. This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332,
as the parties are completely diverse in citizenship and the amount in controversy exceeds
$75,000.
2. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2) in that a substantial part of the
events or omissions giving rise to the claim occurred in this judicial district.
III. PARTIES
3. Plaintiff Arpaio is an individual, natural person who is a citizen of the state of
Arizona.
4. Defendant Zucker is an individual, natural person who is, on information and
belief, a citizen of New York. Defendant Zucker is the President of CNN.
5. Defendant Cuomo is an individual, natural person who is, on information and
belief, a citizen of New York. Defendant Cuomo is a broadcaster for CNN.
6. Defendant CNN is a nationwide news publication that published, as set forth
herein, in this judicial district and with a major news bureau in this judicial district.
2
7. Defendant Robillard is an individual, natural person who is, on information and
belief, a citizen of Maryland.
8. Defendant HuffPo is a nationwide news publication that published, as set forth
herein, in this judicial district and with a major news bureau in this judicial district.
9. Defendant Stuart is an individual, natural person who is, on information and
belief, a citizen of California.
10. Defendant Rolling Stone is a nationwide news publication that published, as set
forth herein, in this judicial district and with a major news bureau in this judicial district.
IV. STANDING
11. Plaintiff Arpaio has standing to bring this action because he has been directly
affected by the unlawful conduct complained herein. Their injuries are proximately related to
the conduct of Defendants.
V. FACTS
Background Facts
12. Plaintiff Arpaio is a long-time member of the law enforcement community who
served as a Washington, D.C. and Las Vegas police officer following his honorable army
discharge in 1953.
13. In November of 1957, Plaintiff Arpaio was appointed as a special agent with the
Federal Bureau of Narcotics, which later became part of the Drug Enforcement Agency
(“DEA”), which is headquartered in Washington, D.C.
14. Following his career with the DEA, Plaintiff Arpaio was elected as sheriff of
Maricopa County, Arizona in 1993. He held that position for almost 25 years or until January 1,
2017.
3
15. In January of 2018, Plaintiff Arpaio announced that he would run for U.S. Senate
in Arizona. He was defeated in the August 28, 2018 Republican primary.
16. Plaintiff Arpaio intends to run for U.S. Senate again in 2020 (as well as pursue
other political and governmental endeavors in this district) for the seat vacated by the late senator
John McCain, which is currently held by John Kyl, a placeholder until the 2020 special election
can take place.
Facts Pertaining to the Defamatory Publications
17. Plaintiff Arpaio has been the target of three separate defamatory publications that
falsely refer to and defamed him per se as a convicted felon. (collectively the “Defamatory
Publications”)
18. On or about January 10, 2018, Defendant CNN aired a feature on national
television that was broadcasted into this judicial district titled Sheriff Joe Arpaio enters Arizona
Senate race1 (the “CNN Broadcast”).
19. The CNN Broadcast featured Defendant Cuomo talking about Plaintiff Arpaio.
20. At the 3-second mark, Defendant Cuomo falsely and with reckless disregard for
the truth stated that Plaintiff Arpaio was a “convicted felon.”
21. Plaintiff Arpaio has never been convicted of a felony.
22. As of today, the CNN Broadcast is still available through Defendant CNN’s
website and no efforts have been taken by Defendant CNN, Defendant Cuomo, or Defendant
Zucker to correct this false statement.
1
Sheriff Joe Arpaio enters Arizona Senate race, CNN, Jan. 10, 2018, available at:
https://www.cnn.com/videos/tv/2018/01/10/joe-arpaio-senate-run-intv.cnn
4
23. On or about November 5, 2018, Defendant HuffPo published an article written by
Defendant Robillard titled Kyrsten Sinema Wants You To Know She’s Not A Progressive. Exhibit
1. (the “HuffPo Article”).
24. In the HuffPo Article, Defendant Robillard falsely claimed and reckless disregard
for the truth that Plaintiff Arpaio had been “sent to prison for contempt of court.”
25. Plaintiff Arpaio has never been sent to prison for contempt of court.
26. As of today, the HuffPo Article is still available through Defendant HuffPo’s
website and no efforts have been taken by Defendant HuffPo or Defendant Robillard to correct
this false statement.
27. On November 13, 2018, Defendant Rolling Stone published an article by
Defendant Stuart titled How Trump Accidentally Helped Democrat Kyrsten Sinema Flip Jeff
Flake’s Arizona Senate Seat. Exhibit 2. (the “Rolling Stone Article”).
28. In the Rolling Stone Article, Defendant Stuart falsely and with reckless disregard
for the truth referred to Plaintiff Arpaio as an “ex-felon.” Plaintiff Arpaio has never been
convicted of a felony.
29. At a later time and date, Defendants Rolling Stone and Stuart silently changed the
contents of its article to say that “Arpaio was convicted of contempt of court, a misdemeanor, in
2017 and pardoned by Trump less than one month later.” Exhibit 3.
30. However, as of today, there is no indication on the Rolling Stone Article that a
mistake had previously been made in referring to Plaintiff Arpaio as an “ex-felon.”
31. Thus, persons who read the Rolling Stone Article when it falsely referred to
Plaintiff Arpaio as an “ex-felon” are not aware that this statement is patently false.
5
32. Plaintiff Arpaio’s distinguished 55-year law enforcement and political career has
been severely harmed, as his reputation has been severely damaged among and with the
Republican establishment, which is centered in the District of Columbia. The false publications
alleged herein all occurred in this district and are continuing.
33. Plaintiff Arpaio’s chances and prospects of election to the U.S. Senate in 2020
have been severely harmed by the publication of false and fraudulent facts in the Defamatory
Article. This also harms Plaintiff financially, as his chances of obtaining funding from the
Republican establishment and donors for the 2020 election have been damaged by the
publication of false and fraudulent representations in the Defamatory Article.
34. Plaintiff Arpaio’s reputation has also been severely harmed in the law
enforcement community, which is centered in this judicial district, and includes the DEA, where
he served for 26 years as an agent and top official.
FIRST CAUSE OF ACTION

Defamation Per Se
35. Plaintiff Arpaio repeats and re-alleges all of the previous allegations of the
entirety of this Complaint with the same force and effect, as if fully set forth herein again at
length.
36. Defendants made and published false and defamatory statements concerning
Plaintiff Arpaio by calling, representing and publishing within this district, the nation and the
world, with malice, that Plaintiff Arpaio had been convicted of a felony.
37. Defendants Zucker, Cuomo, and CNN acted in concert, as Defendant Cuomo
acted at the direction of Defendant Zucker or alternatively his false statements were ratified by
Defendant Zucker, and they all are therefore jointly and severely liable as joint tortfeasors. The
statements were made by Defendant Cuomo and ratified by Defendant Zucker and then
6
published and/or broadcast in this district, nationwide and throughout the world by Defendant
CNN.
38. Defendants Robillard and HuffPo acted in concert and are therefore jointly and
severely liable as joint tortfeasors. The statements were made by Defendant Robillard and then
HuffPo.
39. Defendants Stuart and Rolling Stone acted in concert and are therefore jointly and
severely liable as joint tortfeasors. The statements were made by Defendant Stuart and then
Rolling Stone.
40. Defendants acted with actual malice insofar as they knew that the statements
made against Plaintiff Arpaio were false and/or recklessly disregarded their falsity.
41. Defendants’ statements are defamatory per se insofar as they falsely accuse and
with reckless disregard Plaintiff Arpaio of having been convicted of a felony.
42. Defendants’ statements and the publishing/broadcasting thereof were made
without any privilege.
43. As a direct and proximate result of Defendants and their agents’ extreme,
outrageous and malicious defamatory conduct set forth above, Plaintiff Arpaio has been the
subject of widespread ridicule and humiliation and has suffered severe loss of reputation, which
has in turn also caused him pain and financial damage.
SECOND CAUSE OF ACTION

Tortious Interference with Prospective Business Relations
7
entirety of this Complaint, including with the same force and effect, as if fully set forth herein
again at length.
45. Plaintiff Arpaio has a prospective business relationship with the Republican
National Committee (“RNC”), and its National Republican Senate Campaign Committee
(“NRSC”) which is headquartered in Washington D.C., as well as their affiliated political action
committees and entities and persons, including donors.
46. The RNC and its RNCC, in conjunction with affiliated political action committees
and entities and donors routinely provide funding to Republican political candidates for their
campaigns. Plaintiff Arpaio ran for U.S. Senate in 2018 as a Republican, and intends to run again
for a U.S. Senate seat or other public office in 2020 as a Republican and ardent supporter of
President Donald J. Trump and his administration.
47. Defendants are aware of these prospective business relationships and thus, given
their malice and leftist enmity of Arpaio sought to destroy them with the publication of the
subject Defamatory Publications.
48. Defendants published the Defamatory Publications to influence the RNC, the
RNCC and affiliated political action committee and persons, and other donors, to withhold
funding for Plaintiff Arpaio’s 2020 political campaign by smearing and destroying his reputation
and standing in his law enforcement, government and political community.
49. Plaintiff Arpaio has been harmed as to his reputation as “America’s Toughest
Sheriff” and financially by the publication of the Defamatory Article.
THIRD CAUSE OF ACTION

False Light
8
entirety of this Complaint, including with the same force and effect, as if fully set forth herein
again at length.
51. The Defamatory Publications falsely and very publically portrayed Plaintiff
Arpaio in a negative, false light.
52. The Defamatory Publications contained false statements, representations, or
imputations understood to be of and concerning Plaintiff Arpaio.
53. The Defamatory Publications all falsely accuse Plaintiff Arpaio of having been
convicted of a felony.
54. These statements are misleading and false and made with a reckless disregard for
the truth.
55. These statements, made with malice, place Plaintiff in a false light that would be
offensive to a reasonable person.
56. As a direct and proximate result of Defendants and their agents’ extreme,
outrageous and malicious conduct set forth above, Plaintiff Arpaio has been the subject of
widespread ridicule and humiliation and has suffered severe loss of reputation, which has in turn
also caused him pain and financial damage.
PRAYER FOR RELIEF
W H E R E F O R E , Plaintiffs pray for relief and judgment against each Defendant, jointly
and severally, as joint tortfeasors as follows: actual, compensatory, and punitive damages in
excess of $300,500,000 USD, as well as attorneys’ fees and costs, and any other relief that this
Court may deem just and proper.
DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all counts, as to all issues so triable.
9
DATED: December 10, 2018 Respectfully submitted,
/s/ Larry Klayman

Larry Klayman, Esq.
Chairman and General Counsel
FREEDOM WATCH, INC.
2020 Pennsylvania Ave NW Suite 345
Washington, DC, 20006
Email: leklayman@gmail.com
Tel: 310-595-0800
Counsel for Plaintiff
10
Case 1:18-cv-02894 Document 1-1 Filed 12/10/18 Page 1 of 4
11/13/2018 Who is Kyrsten Sinema?
Case 1:18-cv-02894 Democrat1-2
Document Taking Filed
Jeff Flake’s Arizona Senate
12/10/18 PageSeat 1
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HOME POLITICS POLITICS NEWS NOVEMBER 13, 2018 1:07PM ET
How Trump Accidentally Helped Democrat Kyrsten Sinema Flip

Jeff Flake’s Arizona Senate Seat
The president claimed he “retired” Jeff Flake. He — and the GOP — will regret it
By TESSA STUART
Dem. Kyrsten Sinema, D Ariz. performs the coin toss before an NCAA college football game between Arizona State and
Utah, in Tempe, Arizona, Nov. 3, 2018.
Rick Scuteri/AP/Shutterstock
https://www.rollingstone.com/politics/politics-news/sinema-jeff-flake-seat-arizona-754785/ 1/10
12/10/18 PageSeat 2
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Congresswoman Kyrsten Sinema has officially captured a Republican-held Senate seat in Arizona. Sinema, who at
41 is one of the youngest women ever elected to the Senate, will be the irst openly bisexual senator in U.S.
history. (She also happens to be the first Arizona Democrat elected to the Senate in over 30 years.) The results,
which took almost a full week to tabulate, will come as a disappointment to the president, who bragged the day
after the election when Republican Martha McSally was still leading that he personally “retired” Republican Sen.
Jeff Flake.
A D V E RT I S E M E N T
FROM OUR SPONSOR CONTENT BELOW
“In Jeff Flake’s case it’s me, pure and simple. I retired him. I’m very proud of it, I did the country a great service,”
Trump said during a press conference at the White House a day after the midterm elections. “He is retired. I’d like
to call it another word, but we’re going to treat him with great respect.”
Democrats are likely thrilled with whatever help the president believes he offered. Not only did they figure out the
path to victory in Arizona two years before a special election set to fill a second Senate seat, Democrats defended
the Congressional seat Sinema vacated and flipped the one McSally gave up, too. And they did it by winning the
hearts and minds of a large share of registered Republicans.
McSally and outside groups supporting her bid tried to paint Sinema as too extreme for Arizona, pointing to the
former Green Party candidate’s protest of the Iraq war — in a pink tutu, no less — and her remark, to a radio host
in 2003, that she wouldn’t care if he joined the Taliban. The gambit failed, hard: Sinema peeled off 12 percent
of Arizona’s Republican voters — the highest share of any Democratic Senator, save West Virginia’s Joe Manchin.
Sinema seems well aware of the fact. In her victory speech, she paid tribute to the late Republican senator (and
Trump critic) John McCain. “Senator McCain is irreplaceable, but his example will guide our next steps,” Sinema
told supporters Monday evening. “He taught us to assume the best in others, to seek compromise instead of sewing
division, and to always put country ahead of party. As your Senator, that’s exactly what I’ll do.”
Trump, who was reportedly disappointed that McSally refused to sow doubts about “fraud” in the days it took to
count the outstanding ballots in Arizona, appears to have misjudged his sway with Arizona Republicans — as did
Flake.
12/10/18 PageSeat 3
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FROM OUR SPONSOR CONTENT BELOW
Flake announced he was retiring from the Senate back in October 2017, telling Morning Joe that his brand of
conservatism just didn’t appeal to enough Arizona Republicans. “The bottom line is if I were to run a campaign that
I could be proud of and where I didn’t have to cozy up to the president and his positions or his behavior, I could not
win in a Republican primary,” Flake said. “That’s the bottom line.”
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But McSally, by far the most moderate of the candidates competing, won the Republican primary decisively. She
earned roughly double the number of votes as her closest rival, tea party conspiracist Kelli Ward, and triple the
number of votes of ex-felon and former Maricopa County Sheriff Joe Arpaio.
In This Article: Donald Trump, Jeff Flake, Kyrsten Sinema, Martha McSally
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Document TakingFiled
12/10/18 Page Seat10
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of 10Stone
Case 1:18-cv-02894 Democrat Taking
Document 1-3 Jeff Flake’s
Filed Arizona Senate
12/10/18 Seat –1Rolling
Page of 2 Stone
How Trump Accidentally
Helped Democrat Kyrsten The president claimed he “retired” Jeff Flake. He — and
By TESSA STUART
the GOP — will regret it
Sinema Flip Jeff Flake’s
Arizona Senate Seat
Dem. Kyrsten Sinema, D-Ariz. performs the coin toss before an NCAA college football game between Arizona State and Utah, in Tempe, Arizona, Nov. 3, 2018.
Rick Scuteri/AP/Shutterstock
Congresswoman Kyrsten Sinema has officially captured a Republican-held Senate seat in Arizona. Sinema, who at 41 is one of the youngest women ever
elected to the Senate, also happens to be the first Arizona Democrat elected to the Senate in over 30 years. The results, which took almost a full week to
tabulate, will come as a disappointment to the president, who bragged the day after the election when Republican Martha McSally was still leading that he
personally “retired” Republican Sen. Jeff Flake.
“In Jeff Flake’s case it’s me, pure and simple. I retired him. I’m very proud of it, I did the country a great service,” Trump said during a press conference at
the White House a day after the midterm elections. “He is retired. I’d like to call it another word, but we’re going to treat him with great respect.”
Democrats are likely thrilled with whatever help the president believes he offered. Not only did they figure out the path to victory in Arizona two years
before a special election set to fill a second Senate seat, Democrats defended the Congressional seat Sinema vacated and flipped the one McSally gave up,
too. And they did it by winning the hearts and minds of a large share of registered Republicans.
McSally and outside groups supporting her bid tried to paint Sinema as too extreme for Arizona, pointing to the former Green Party candidate’s protest of
the Iraq war — in a pink tutu, no less — and her remark, to a radio host in 2003, that she wouldn’t care if he joined the Taliban. The gambit failed,
hard: Sinema peeled off 12 percent of Arizona’s Republican voters — the highest share of any Democratic Senator, save West Virginia’s Joe Manchin.
Sinema seems well aware of the fact. In her victory speech, she paid tribute to the late Republican senator (and Trump critic) John McCain. “Senator
McCain is irreplaceable, but his example will guide our next steps,” Sinema told supporters Monday evening. “He taught us to assume the best in others, to
seek compromise instead of sewing division, and to always put country ahead of party. As your Senator, that’s exactly what I’ll do.”
Trump, who was reportedly disappointed that McSally refused to sow doubts about “fraud” in the days it took to count the outstanding ballots in Arizona,
appears to have misjudged his sway with Arizona Republicans — as did Flake.
Flake announced he was retiring from the Senate back in October 2017, telling Morning Joe that his brand of conservatism just didn’t appeal to enough
Arizona Republicans. “The bottom line is if I were to run a campaign that I could be proud of and where I didn’t have to cozy up to the president and his
positions or his behavior, I could not win in a Republican primary,” Flake said. “That’s the bottom line.”
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Case 1:18-cv-02894 Democrat Taking
Document 1-3 Jeff Flake’s
Filed Arizona Senate
12/10/18 Seat –2Rolling
Page of 2 Stone
But McSally, by far the most moderate of the candidates competing, won the Republican primary decisively. She earned roughly double the number of
votes as her closest rival, tea party conspiracist Kelli Ward, and triple the number of votes of presidential pardonee and former Maricopa County sheriff,
Joe Arpaio. (Arpaio was convicted of contempt of court, a misdemeanor, in 2017 and pardoned by Trump less than one month later.)
CIVIL COVER SHEET
JS-44 (Rev. 6/17 DC)
I. (a) PLAINTIFFS DEFENDANTS
Joseph Michael Arpaio Jeff Zucker, Chris Cuomo, CNN, Kevin Robillard, Huffington
Post, Tessa Stuart, Rolling Stone
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________ COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN)
Klayman Law Group, P.A.

2020 Pennsylvania Ave NW #800
Washington, DC 20006
310-275-4963
II. BASIS OF JURISDICTION III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR
(PLACE AN x IN ONE BOX ONLY) PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
PTF DFT PTF DFT
o 1 U.S. Government o 3 Federal Question
Plaintiff (U.S. Government Not a Party) Citizen of this State o1 o1 Incorporated or Principal Place o4 o4
of Business in This State
o 2 U.S. Government o 4 Diversity Citizen of Another State o2 o2 Incorporated and Principal Place o5 o5
Defendant (Indicate Citizenship of
of Business in Another State
Parties in item III) Citizen or Subject of a
Foreign Country
o3 o3 Foreign Nation o6 o6
IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)
o A. Antitrust o B. Personal Injury/ o C. Administrative Agency o D. Temporary Restraining
Malpractice Review Order/Preliminary
410 Antitrust Injunction
310 Airplane 151 Medicare Act
315 Airplane Product Liability Any nature of suit from any category
320 Assault, Libel & Slander Social Security
may be selected for this category of
861 HIA (1395ff)
330 Federal Employers Liability case assignment.
862 Black Lung (923)
340 Marine
863 DIWC/DIWW (405(g)) *(If Antitrust, then A governs)*
345 Marine Product Liability
864 SSID Title XVI
350 Motor Vehicle
865 RSI (405(g))
355 Motor Vehicle Product Liability
Other Statutes
360 Other Personal Injury
891 Agricultural Acts
362 Medical Malpractice
893 Environmental Matters
365 Product Liability
890 Other Statutory Actions (If
367 Health Care/Pharmaceutical
Administrative Agency is
Personal Injury Product Liability
Involved)
368 Asbestos Product Liability
o E. General Civil (Other) OR o F. Pro Se General Civil

Real Property Bankruptcy Federal Tax Suits 462 Naturalization
210 Land Condemnation 422 Appeal 27 USC 158 870 Taxes (US plaintiff or Application
220 Foreclosure 423 Withdrawal 28 USC 157 defendant) 465 Other Immigration
230 Rent, Lease & Ejectment 871 IRS-Third Party 26 USC Actions
240 Torts to Land Prisoner Petitions 7609 470 Racketeer Influenced
245 Tort Product Liability 535 Death Penalty
& Corrupt Organization
540 Mandamus & Other Forfeiture/Penalty
290 All Other Real Property 480 Consumer Credit
550 Civil Rights 625 Drug Related Seizure of
Property 21 USC 881 490 Cable/Satellite TV
Personal Property 555 Prison Conditions
690 Other 850 Securities/Commodities/
370 Other Fraud 560 Civil Detainee – Conditions
Exchange
371 Truth in Lending of Confinement
Other Statutes 896 Arbitration
380 Other Personal Property
375 False Claims Act 899 Administrative Procedure
Damage Property Rights
820 Copyrights 376 Qui Tam (31 USC Act/Review or Appeal of
385 Property Damage
830 Patent 3729(a)) Agency Decision
Product Liability
835 Patent – Abbreviated New 400 State Reapportionment 950 Constitutionality of State
Drug Application 430 Banks & Banking Statutes
840 Trademark 450 Commerce/ICC 890 Other Statutory Actions
Rates/etc. (if not administrative agency
460 Deportation review or Privacy Act)
o G. Habeas Corpus/ o H. Employment o I. FOIA/Privacy Act o J. Student Loan
2255 Discrimination
530 Habeas Corpus – General 442 Civil Rights – Employment 895 Freedom of Information Act 152 Recovery of Defaulted
510 Motion/Vacate Sentence (criteria: race, gender/sex, 890 Other Statutory Actions Student Loan
463 Habeas Corpus – Alien national origin, (if Privacy Act) (excluding veterans)
Detainee discrimination, disability, age,
religion, retaliation)
*(If pro se, select this deck)* *(If pro se, select this deck)*
o K. Labor/ERISA o L. Other Civil Rights o M. Contract o N. Three-Judge

(non-employment) (non-employment) Court
110 Insurance
710 Fair Labor Standards Act 441 Voting (if not Voting Rights 120 Marine 441 Civil Rights – Voting
720 Labor/Mgmt. Relations Act) 130 Miller Act (if Voting Rights Act)
740 Labor Railway Act 443 Housing/Accommodations 140 Negotiable Instrument
751 Family and Medical 440 Other Civil Rights 150 Recovery of Overpayment
Leave Act 445 Americans w/Disabilities – & Enforcement of
790 Other Labor Litigation Employment Judgment
791 Empl. Ret. Inc. Security Act 446 Americans w/Disabilities – 153 Recovery of Overpayment
Other of Veteran’s Benefits
448 Education 160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise
V. ORIGIN
o 1 Original o 2 Removed o 3 Remanded o 4 Reinstated o 5 Transferred o 6 Multi-district o 7 Appeal to o 8 Multi-district
Proceeding from State from Appellate or Reopened from another Litigation District Judge Litigation –
Court Court district (specify) from Mag. Direct File
Judge
VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)
Defamation, False Light, Tortious Interference
VII. REQUESTED IN CHECK IF THIS IS A CLASS DEMAND $ Check YES only if demanded in complaint
ACTION UNDER F.R.C.P. 23 YES NO
COMPLAINT JURY DEMAND:
VIII. RELATED CASE(S) (See instruction) If yes, please complete related case form
YES NO
IF ANY
12/10/2018
DATE: _________________________ /s/ Larry Klayman
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44

Authority for Civil Cover Sheet
The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.
III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.
IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best
represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding
nature of suit found under the category of the case.
VI. CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause.
VIII. RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from
the Clerk’s Office.
Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT

for the
__________ District
District of __________
of Columbia
Joseph Michael Arpaio )

)
)
)
Plaintiff(s) )
)
v. Civil Action No. 18-2894
)
Jeff Zucker, et al )
)
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) JEFF ZUCKER, an individual

1 CNN Center
Atlanta, GA, 30303
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Klayman Law Group P.A.
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 18-2894
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)

was received by me on (date) .
’ I personally served the summons on the individual at (place)

on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print Save As... Reset


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) TESSA STUART, an individual

c/o Rolling Stone
New York , NY 10104
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) ROLLING STONE, a corporation

New York, NY 10104
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) KEVIN ROBILLARD, an individual

c/o Huffington Post
770 Broadway
New York, NY 10003
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) HUFFINGTON POST, a corporation

770 Broadway
New York, NY 10003
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) CHRIS CUOMO, an individual

1 CNN Center
Atlanta, GA, 30303
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address


for the
__________ District
of Columbia

)
)
)
Plaintiff(s) )
)
)
)
)
)
Defendant(s) )
To: (Defendant’s name and address) CABLE NEWS NETWORK, a corporation

1 CNN Center
Atlanta, GA, 30303
Date:
PROOF OF SERVICE


on (date) ; or

on (date) ; or
.
Date:
Server’s address

Joe Arpaio Files Defamation Complaint Against CNN, Other Media

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Joe Arpaio Files Defamation Complaint Against CNN, Other Media

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Case 1:18-cv-02894 Document 1 Filed 12/10/18 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT

JOSEPH MICHAEL ARPAIO, an individual

(“Stuart”) and Rolling Stone (“RS”).

II. JURISDICTION AND VENUE

2. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2) in that a substantial part of the

3. Plaintiff Arpaio is an individual, natural person who is a citizen of the state of

4. Defendant Zucker is an individual, natural person who is, on information and

belief, a citizen of New York. Defendant Zucker is the President of CNN.

5. Defendant Cuomo is an individual, natural person who is, on information and

belief, a citizen of New York. Defendant Cuomo is a broadcaster for CNN.

6. Defendant CNN is a nationwide news publication that published, as set forth

7. Defendant Robillard is an individual, natural person who is, on information and

belief, a citizen of Maryland.

8. Defendant HuffPo is a nationwide news publication that published, as set forth

9. Defendant Stuart is an individual, natural person who is, on information and

belief, a citizen of California.

the conduct of Defendants.

(“DEA”), which is headquartered in Washington, D.C.

in Arizona. He was defeated in the August 28, 2018 Republican primary.

can take place.

Facts Pertaining to the Defamatory Publications

Senate race1 (the “CNN Broadcast”).

the truth stated that Plaintiff Arpaio was a “convicted felon.”

21. Plaintiff Arpaio has never been convicted of a felony.

Zucker to correct this false statement.

23. On or about November 5, 2018, Defendant HuffPo published an article written by

1. (the “HuffPo Article”).

this false statement.

27. On November 13, 2018, Defendant Rolling Stone published an article by

Flake’s Arizona Senate Seat. Exhibit 2. (the “Rolling Stone Article”).

mistake had previously been made in referring to Plaintiff Arpaio as an “ex-felon.”

alleged herein all occurred in this district and are continuing.

publication of false and fraudulent representations in the Defamatory Article.

he served for 26 years as an agent and top official.

FIRST CAUSE OF ACTION

with reckless disregard Plaintiff Arpaio of having been convicted of a felony.

42. Defendants’ statements and the publishing/broadcasting thereof were made

without any privilege.

has in turn also caused him pain and financial damage.

SECOND CAUSE OF ACTION

committees and entities and persons, including donors.

President Donald J. Trump and his administration.

subject Defamatory Publications.

and standing in his law enforcement, government and political community.

Sheriff” and financially by the publication of the Defamatory Article.

THIRD CAUSE OF ACTION

Arpaio in a negative, false light.

52. The Defamatory Publications contained false statements, representations, or

imputations understood to be of and concerning Plaintiff Arpaio.

offensive to a reasonable person.

also caused him pain and financial damage.

PRAYER FOR RELIEF

Court may deem just and proper.

DEMAND FOR JURY TRIAL

DATED: December 10, 2018 Respectfully submitted,

/s/ Larry Klayman

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